Welcome to the HomeExchange.com, a website operated by HomeExchange.com
Inc. and its affiliates (together, “HomeExchange”). This Policy (“ Privacy Policy”) describes what information HomeExchange
may collect about its visitors and Members through HomeExchange.com and/or
its affiliated websites (“Affiliated Websites”)
(HomeExchange and its Affiliated Websites, collectively “ HomeExchange,” the “Websites” or “we”)
may collect about visitors (“you”) and what we may do with that
information. Our Affiliated Websites can be found here.
Please note that your use of the Websites and your HomeExchange membership
are also governed by other agreements including the Terms of Use and
Membership (“Terms of Use and Membership”). In case of any
conflict among this Privacy Policy and the Terms of Use and Membership, the
Terms of Use and Membership shall govern unless expressly stated therein.
By using the Website, you agree to be bound by this Privacy Policy.

BY USING OR ACCESSING THE WEBSITES, YOU CONFIRM YOUR ASSENT AND
ACKNOWLEDGMENT TO THE PRIVACY POLICY SET FORTH BELOW. IF YOU DO NOT AGREE
WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEBSITES. WE RESERVE THE
RIGHT TO REVISE THIS PRIVACY POLICY AT ANY TIME. YOUR USE AFTER SUCH CHANGE
CONFIRMS YOUR ACCEPTANCE OF THE CHANGED TERMS. PLEASE CHECK THIS POLICY
PERIODICALLY FOR CHANGES.

Capitalized terms used but not defined herein have the meanings assigned to
them in the HomeExchange Terms of Use and Membership.

I. INFORMATION WE COLLECT

We collect three general categories of information – information you
provide to us, information we collect automatically through your use of the
Websites, and information we collect from third parties.

A. Information You Provide to Us

When you become a Member of HomeExchange, you will be asked to provide
information for three separate pages: your “Account,” your “Profile,” and
your “Listing.” The following describes the information you may be asked to
provide for each page. Any information provided may be updated at any time.

Account Information.
When you create a membership account, we or our service providers may
collect information that could reasonably be used to contact you or to
identify you personally, such as your name, email address, telephone
number, mobile phone number, geographic location, or mailing address (“ Personal Information”). This information, unless shared
voluntarily by you, shall remain confidential.

Profile Information.
Following the creation of your membership account, you may complete a
profile, visible to all visitors to the Website, that includes information
about you, your interests, and any other information that you choose to
share with other Members about yourself.

Listing Information
. Once you decide to offer your property for an Exchange, you will create a
Listing. This Listing will contain information about the property and its
location, and will provide a link to your Profile page. All of this
information will be visible to all visitors to the Website.

Authentication Information.
When using the Websites, you may be asked to provide us with certain
information to authenticate your identity or a transaction.

Posts, Messages, and Communications on the Websites.
When you post on the Websites, communicate with other Members through the
HomeExchange Messaging System, or contact us, we may collect information
about these communications, including any information you choose to
provide.

Payment Information.
When you sign up as a Member of HomeExchange, we or our third-party payment
provider may collect your financial information such as your name, address,
credit card number or PayPal account number or other information to process
transactions.

Other Information.
You may otherwise choose to provide us with information when you fill in a
form, conduct a search, respond to surveys, participate in promotions, or
use other features on the Website.

If you change your email address, we may retain a record of your email
address. You can also change your Account information such as your name,
address, city, state, zip code, country, phone number, and saved search
criteria, as well as any information on your Profile or Listing(s).

Note that even once we remove you from our database, your information may
not be completely deleted due to technical and legal constraints.
Therefore, you should not expect that all of your Personal Information will
be completely removed in response to any request you may submit.

2. Your Use of Other Members’ Information

By accepting this Privacy Policy, you agree that, with respect to other
Members’ Personal Information that you obtain through HomeExchange,
HomeExchange hereby grants to you a license to use such information only
for: (a) HomeExchange-related communications that are not unsolicited
commercial messages, and (b) any other purpose to which such Member
expressly agrees after complete disclosure of the purpose. In addition,
under no circumstances, except as defined in this Privacy Policy, may you
disclose personally identifiable information about another Member to any
third party without the consent of such other Member after adequate
disclosure. HomeExchange and our Members do not tolerate spam. Therefore,
without limiting the foregoing, you are not permitted to add a Member to
your mailing list (email or physical mail) without his or her express
consent, after adequate disclosure.

3. Passwords

You are responsible for all actions taken with your login information and
password. Therefore, we do not recommend that you disclose your password or
login information to any third party. If you choose to share this
information with any third party, you are responsible for all actions taken
with your login information and password, and therefore should review each
third party's Privacy Policy. If you lose control of your password, you may
lose substantial control over your personally identifiable information and
may be subject to legally binding actions taken on your behalf. Therefore,
if your password has been compromised in any way, you should immediately
change your password.

We urge you to protect your own privacy. We recommend that you do not share
your password with anyone or share your password in an unsolicited phone
call or email.

B. Information We Collect Automatically

Log Data.
Whenever you visit or interact with the Websites, we may use a variety of
technologies that automatically or passively collect information about how
you access or use the Websites (“Usage Information”) even
if you are not a Member. Usage Information may include your browser type,
operating system, hardware and software information, the page served, the
time, and the preceding page views. However, this information does not
identify you as an individual user. We do not treat Usage Information as
Personal Information unless it is combined with other data that, once
linked, can be used to identify you.

Device Identifiers
. We also may automatically collect your IP address or other unique
identifier (“Device Identifier”) for the computer, mobile
device, technology, or other device (collectively, “Device
”) you use to access the Websites. A Device Identifier is a number that is
automatically assigned to your Device when you access a website or its
servers, and our computers identify your Device by its Device Identifier.
We may use a Device Identifier to, among other things, administer the
Websites, help diagnose problems with our servers, analyze trends, track
users’ web page movements, help identify, and gather broad demographic
information for aggregate use.

Mobile Identifiers.
We may use software development kits (“SDKs”) or mobile
advertising identifiers (for example, “IDFA” on Apple
mobile devices or “Advertising ID” on Android mobile
devices), which function similarly to cookies on mobile devices. You may
reset your IDFA or Advertising ID in the settings on your mobile device.

Location Information.
When you use the Websites, we may collect certain types of information
about your general location (such as your IP address or zip code) or more
precise location information such as your mobile GPS. Your mobile device
may allow you to enable or disable the use of location-based services for
your device in the Settings menu.

Third-Party Social Plugins.
The Websites may allow you to use social plugins which are provided and
operated by third parties such as Facebook’s “Log in” feature or “Like”
button. When you use these social plugins, you may send these third parties
information that you are viewing a certain part of the Websites. If you are
logged into your account with the third party, then the third party may be
able to link information about your visit to the Websites to your account
with that third party. Similarly, they may record your interactions with
the social plugin and our Websites. Refer to the third parties’ privacy
policies to learn more about their social plugins.

1. Cookies and Tracking Pixels

Cookies.
We use data collection devices such as “cookies” on certain pages of the
Websites. Cookies are small files placed on your hard drive that assist us
in providing customized services. We also offer certain features that are
only available through the use of cookies. Cookies can also help us provide
information which is targeted to your interests. We use this information to
determine your demographics, interests, and behavior to better understand
and serve you and our community. This information may include the URL of
the website that you visited prior to the Websites (whether this is on our
site or not), the URL of the website you next go to (whether this URL is on
our site or not), what browser you are using, and your Internet Protocol
(“IP”) address. Most cookies are “session cookies”, meaning that they are
automatically deleted from your hard drive at the end of a session. You are
always free to decline our cookies if your browser permits.

Tracking Pixels and Third Parties.
We may use a third-party advertising company to post ads on our behalf
across the Internet. That advertising company may also collect anonymous
information about your visits to the Websites. This is primarily
accomplished through the use of a device commonly referred to as a Web
beacon, cookie, or an action tag, which is placed on various web pages
within the Websites or in an HTML e-mail that allows the third-party
advertising company to collect anonymous information. Some of the
third-party advertisers that we use have their own privacy policies and may
allow you to opt out of having your information collected as discussed
above. The “Help” section of your browser may tell you how to prevent your
browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

2. Do Not Track

We may collect information about you or your use of the Websites through
cookies, tracking pixels, web beacons, mobile identifiers, or other
technologies. We use this information to better understand, customize and
improve the Websites, services, and offerings as well as to manage our
advertising. The information we collect through cookies, tracking pixels,
web beacons or mobile identifiers may help us understand how visitors use
and engage with the Websites. If you have provided us with your Personal
Information, for example, when you registered for an account or requested
information from us, we may associate this Personal Information with
information we have collected through cookies, tracking pixels, web beacons
mobile identifiers or other technologies.

Some web browsers may transmit “do-not-track” signals to the websites with
which the user communicates. Because of differences in how web browsers
incorporate and activate this feature, it is not always clear whether users
intend for these signals to be transmitted, or whether they even are aware
of them. Because there currently is no industry standard concerning what,
if anything, websites should do when they receive such signals, the
Websites do not currently act in response to these signals. If and when a
final standard is established and accepted, we will reassess how to respond
to these signals. For more information about “Do Not Track,” please visit www.allaboutdnt.org.

II. HOW WE USE YOUR INFORMATION

Our primary goal in collecting Personal Information is to provide you with
a smooth, efficient, and customized experience. This allows us to provide
services and features and to customize our service to make your experience
better.

Any information you submit on the Websites may be used for a variety of
purposes, including, for example, to:

· respond to your questions and requests;

· provide you with access to certain features of the Websites;

· verify your identity;

· improve the Websites;

· communicate with you;

· contact a Member on your behalf;

· attempt to resolve a dispute;

· discuss a transaction on the Websites;

· improve our marketing and promotional efforts;

· improve our content and product offerings;

· send you relevant promotions, personalized information, or updates or
newsletters with information that you have requested or may be of interest
to you;

· Enforce this Privacy Policy or our Terms of Use and Membership;

· contact you with regard to your use of the Websites, an Exchange or a
posting; and

· in our discretion, to make changes to the Websites or any of our
policies.

We will only use the information you provide to us in a manner that is
consistent with this Privacy Policy or where we have otherwise obtained
your consent.

There may be instances arising out of a verified Exchange where one Member
to the Exchange may have an urgent need for contact information of the
other Member to the Exchange. In those instances, we may, in our sole and
absolute discretion, provide a Member's contact information to the other
Member of such verified Exchange.

We may also use your Personal Information to contact you and to deliver
information to you that, in some cases, is targeted to your interests, such
as targeted banner advertisements, administrative notices, product
offerings, and communications relevant to your use of the Websites. By
using the Websites, you expressly agree to receive this information. If you
do not wish to receive these communications, you may opt out of the receipt
of certain communications through the link provided in those
communications.

Members.
As a Member, we may feature your Listings in editorials and newsletters
that we may periodically send out to our Members. The only information from
your Listings that we will include in these editorials or newsletters will
be the information which you chose to display when you created such
Listing.

As described above, your Profile and Listings can be viewed by other
Members and the general public and we cannot prevent third parties from
copying and displaying information which is posted. To the extent you do
not want certain information to be viewed, do not place that information in
your Profile or Listing. We may, through agreements with other websites,
allow your Listing information to be posted on such other websites. Such
postings will not include any of your Personal Information (including any
contact information), nor will we allow those websites or their users to
contact you directly, but we will instead have those users re-directed to
the Websites and/or your Listing on the Websites.

Communications.
We may, either directly or through third parties we engage to provide
services to us, review, scan, or analyze your communications with other
Members on the Websites for fraud prevention, risk assessment, regulatory
compliance, investigation, product development, research, and customer
support purposes. We also may scan, review, or analyze messages for
research and product development purposes to help make searches, Exchange
registrations, and Member communications more efficient and effective, as
well as to debug, improve and expand product offerings. By using the
Websites, you consent to allow us, in our sole discretion, either directly
or through third parties we engage to provide services to us, review, scan,
analyze, and store your communications, whether done manually or through
automated means.

III. HOW WE MAY SHARE YOUR INFORMATION

As a matter of policy, we do not sell or rent any Personal
Information about you to any third party. However, there are certain
situations where we may use or disclose your Personal Information. Although
we use industry standard practices to protect your privacy, we do not
promise, and you should not expect, that your Personal Information or
private communications will always remain private. HomeExchange shall not
be liable for any claims or damages arising from the use of your Personal
Information by any third party.

A. Financial Information

We may collect and use your payment information, including your name,
address, credit card number or PayPal account number and other information
to bill you for your Membership and use of our services. By buying a
Membership, or engaging in any other kind of activity or transaction that
uses financial information on the Websites, you consent to our providing of
your financial information to our service providers and to such third
parties as we determine necessary to support and process transactions. We
may also contact your credit card issuer or your banking institution for
their assistance with processing and supporting your transaction or
activity.

By participating in programs offered on the Websites that are administered
by third parties (that may require you to submit certain information, such
as the address of your property offered on your Listing), you also consent
to our providing your such information to those third parties. Any of these
third parties may be authorized to use your information in accordance with
its own Privacy Policy and any contracts made between it and HomeExchange.

B. Advertisers

We may aggregate information provided on your Listing about your property
and disclose such information in an anonymized manner to advertisers and
other third parties for marketing and promotional purposes. However, in
these situations, we do not disclose to these entities any information that
could be used to identify you personally. Certain information, such as your
name, email address, password or credit card number is never disclosed to
these third parties.

C. Service Providers

We may share your Personal Information with third parties that perform
functions on our behalf (“Service Providers”) to carry out
your requests, respond to your inquiries or make various features of the
Websites available to you. These Service Providers may help us to host or
operate the Websites, analyze data, provide customer service, conduct
marketing, or administer surveys or questionnaires.

D. Business Transfers

We may share your information, including your Personal Information with our
subsidiaries and affiliates for internal reasons, primarily for business
and operational purposes. We may share or transfer your information,
including your Personal Information in connection with a merger, sale,
acquisition, divestiture, restructuring, reorganization, dissolution,
bankruptcy, or other change of ownership or control by HomeExchange or any
affiliated company (in each case, whether in whole or in part).

E. Legal Disclosure

We may transfer and/or disclose your information, including your Personal
Information, to third parties to comply with a legal obligation, when we
believe in good faith that the law requires it, at the request governmental
authorities conducting an investigation, to verify or enforce this Privacy
Policy, our Terms of Use and Membership, or other applicable policies. We
may also transfer and/or disclose your information, including your Personal
Information to respond to an emergency, or otherwise protect the rights,
property, safety, or security of HomeExchange, third parties, Members, or
users of the Websites. We can (and you authorize us to) disclose any
information about you to law enforcement and other government officials as
we, in our sole discretion, believe necessary or appropriate, in connection
with any investigation of fraud, intellectual property infringements, or
other activity that is illegal or may expose us or you to legal liability.

IV. DEACTIVATING YOUR ACCOUNT

To deactivate your Account, please contact us. Upon
your notification, we will remove your Membership from our active databases
as soon as reasonably possible in accordance with this Privacy Policy and
applicable law, typically within three (3) days. You also can hide or
remove your Profile or Listing so that others cannot view it. To learn
more, please visit the Help section of the Websites.

After deactivating your Account, we will retain your Account
information for only as long as is necessary for the purposes to which you consent under
the Terms of Use and Membership and this Privacy Policy, or as is required
by applicable law, and then we will delete it. We may
use this information for certain purposes, such as to resolve disputes,
troubleshoot problems and enforce our Terms of Use and Membership. Further,
once we delete this information, it may not be completely removed from our
databases due to technical and legal constraints, including stored or other
backup copies. Therefore, you should not expect that all of your Account
information will be completely removed from our databases in response to
any request you may submit.

V. LINKS TO OTHER WEBSITES AND SHARING INFORMATION WITH THIRD PARTIES

The Websites may offer a number of services from external service providers
that help you use the Websites or enjoy the benefits of Membership. If you
choose to use these optional services, and in the course of doing so
disclose information (including your Personal Information) to these
external service providers, and/or grant them permission to collect
information about you, then their use of your information is governed by
their private policies, if any.

The Websites also may contain links to other sites maintained by third
parties. These links are provided only as a convenience to you.
HomeExchange has no control over, and is not responsible for any content,
products, or services offered by or found on third party sites, or their
privacy practices which may govern their use of your information. Links to
these third party sites do not constitute an assumption of liability for or
sponsorship, endorsement, or approval by us of these sites or the content
contained on these sites.

To the extent that you disclose your information to other parties, whether
they are on the Websites or on other sites, different rules may apply to
their use or disclosure of the information you disclose to them. To the
extent that we use third party advertisers, they adhere to their own
privacy policies. Since HomeExchange does not control the privacy policies
of any third parties, you should investigate their policies before you
disclose your personal information to them.

VI. CHILDREN

Children are not eligible to use the Websites or our services, and we ask
that children under thirteen (13) years of age not submit any Personal
Information to us.

We do not knowingly collect information from children under thirteen (13)
years of age. If we learn that a child under the age of thirteen (13) has
provided us with any Personal Information without first receiving their
parent or guardian’s verified consent, we will use that information only to
respond directly to that child (or his or her parent or legal guardian) to
inform the child that he or she cannot use the Websites. We will then
dispose of such Personal Information in accordance with this Privacy
Policy. If you believe we may have any information from or about a child
under the age of (thirteen) 13, please contact us at
support@homeexchange.com.

VII. ACCESSING THE WEBSITES GLOBALLY – TRANSFER OF DATA

The Websites are governed by, operated in, and in accordance with the laws
of the United States. Your Personal Information will be stored and
processed on our servers located in the United States. While the laws
regarding the handling of Personal Information in the United States may
differ from the laws of other countries we make no representation that the
Websites or the use of your Personal Information will be governed by or
operated in accordance with the laws of any other nation.

If you are located in the European Union, Canada, or elsewhere outside of
the United States, please be aware that information we collect may be
transferred to and processed in the United States. By using the Websites,
or providing us with any information, you (a) acknowledge that the Websites
are subject to the laws of the United States, (b) consent to the
collection, processing, maintenance, and transfer of such information in
and to the United States and other applicable territories in which the
privacy laws may not be as comprehensive as or equivalent to those in the
country where you reside and/or are a citizen, and (c) waive any claims
that may arise under those laws.

VIII. YOUR CALIFORNIA PRIVACY RIGHTS

California residents are entitled once a year, free of charge, to request
and obtain certain information regarding our disclosure, if any, of
personally identifiable information to third parties for their direct
marketing purposes in the preceding calendar year (e.g., requests made in
2017 will receive information about 2016 sharing activities). We comply
with this law by giving users the ability to tell us not to share
personally identifiable information with third parties for their direct
marketing purposes. To make such a request, send an email to
support@homeexchange.com. We may need additional information to process
your request.

IX. SECURITY MEASURES

HomeExchange uses certain reasonable industry practices, including
“firewalls” and Secure Socket Layers, to safeguard the confidentiality of
your Personal Information. We treat data as an asset that must be protected
against loss and unauthorized access. We employ many different security
techniques to protect such data from unauthorized access by others inside
and outside the company. However, no electronic data transmission or
storage of information can be guaranteed to be 100% secure. Please note
that we cannot ensure or warrant the security of any information you
transmit to us, and you use the Websites and provide us with your
information at your own risk.

X. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If this Privacy Policy
changes in a way that significantly affects how we handle your Personal
Information, we will not use the Personal Information we currently maintain
without providing you notice, where appropriate.
We will notify you about any changes to this Privacy Policy by changing
the “Last Updated” date at the top of the
Privacy Policy. We encourage you to review this page for the latest
information about our privacy practices.

XI. CONTACT US

If you have any questions or concerns about this Privacy Policy, please
contact us by email at support@homeexchange.com or write us at:

HomeExchange Inc.

45 Prospect St.

Cambridge, MA 02139
USA

XII. Our use of cookies

We use cookies and trackers for various reasons:

A. Technical cookies

We need to store these cookies so that you can use the basic functions of
our website and to offer you improved, personalised functions.

For example, technical cookies will allow us to know that you are
connected, to offer you the language of your choice, to display the website
according to your display preferences, to better manage the load on our
servers, etc.

B. Audience measurement cookies

We place these cookies to better understand how you browse our website,
what other website you came from, what content will get your attention,
which pages you visit most regularly, etc. This allows us to improve our
service.

C. Advertising cookies

We place advertising cookies to display ads that may be of interest to you.
These advertising cookies collect your browsing habits on our website
and/or on other websites on which these cookies are also present in order
to create a profile of your interests. These third-party cookies are
produced by the advertising agencies themselves.

For these advertising cookies, you can also indicate your objection to
tracking cookies Your Online Choices:
http://youronlinechoices.com/fr/controler-ses-cookies/
, offered by the digital advertising professionals grouped within the
European association EDAA (European Digital Advertising Alliance).

D. Social network / third-party cookies

We place social network cookies to allow you to share content on the
leading social networks. These third-party cookies are produced by the
social networks themselves.

XIV. Your rights

You have several rights with respect to your information that we possess:

Right of access

You may ask us to access any information we hold about
you.

Right to rectification

You may ask us to correct your information.

Most of the time, you can make corrections yourself
when you are connected to our website.

Right to object

You may ask us to stop using your information when we
do so because of a legitimate interest.

You may also ask us to stop sending you direct
marketing / prospecting messages. You can easily do
this when you are connected to our website by going to
the ‘My Profile’ tab and then ‘Settings’ or by
unsubscribing by clicking on the link provided at the
bottom of our emails.

Right to withdraw consent

Where you have given us your consent to use your
information for a specific purpose, you may, at any
time, decide to withdraw your consent and we will then
stop using your information for that purpose.

You can easily do this when you are connected to our
website by going to the ‘My Profile’ tab and then
‘Settings’

Right to erasure or right to be forgotten

You may ask us, via email to our data protection
officer, to delete your information or to stop using
it.

We can only do this when possible: sometimes we need
your information to comply with the law or simply to
provide you with our services.

Right to restriction of processing

You may ask our data protection officer by email to
block the use of your information, i.e. to temporarily
store it but to stop using it.

Right to portability

You may contact our data protection officer to request
an export of your information in a reusable format.

Right to lodge a complaint

You may lodge a complaint with the authority
responsible for protecting personal data (in France,
the CNIL www.cnil.fr
) if you believe that your rights have not been
respected.

XV. Exercising your rights

To exercise your rights, contact our data protection officer (DPO) at the
address given in section 16 of the Charter.

We will do our best to answer you within one month.

Any refusal of a request will be documented and explained.

Proof of identity is required for all requests to exercise rights (except
in special exceptions).

XVI. Your DPO contact

Protecting your information is important to us. That is why we have
appointed a data protection officer. He or she is the best person to answer
all your questions about personal data.